Bizkaia: What is TicketBAI Invoicing?

Carolina Silva
May 15, 2023

What is TicketBAI?

TicketBAI is a joint project of the Provincial Treasuries and the Government of the Basque Country with the objective of implementing a series of legal and technical obligations for the taxpayers’ invoicing software.

These obligations allow the tax authorities to control their economic activities, especially those in the sector of sales of goods and provisions of services. TicketBAI is a joint project, but each region has its particularities in the implementation and sending of files.

TicketBAI is an invoicing software that follows specific standards to guarantee the integrity, conservation, traceability and inviolability of records that document the supply of goods and services. This compliant invoicing system is also called “guarantor software”.


Who is affected by TicketBAI?

The TicketBAI mandate applies to all taxpayers, whether a person or a business, that operate economically in a way which falls under the Basque Regional Treasuries regulations. However, the details of the mandate and implementation dates are unique across Bizkaia, Álava and Gipuzkoa.


What is TicketBAI in Bizkaia?

TicketBAI invoicing is one of the three elements in Bizkaia’s Batuz tax control strategy, devised with the aim of reducing tax tampering in the region.

Taxpayers subject to Batuz will be obliged to issue invoices using TicketBAI-compliant software, which must meet technical specifications and functional characteristics established by law.

Bizkaia’s TicketBAI system has particularities compared with TicketBAI in other regions of the Basque country, so understanding specific requirements in each province is crucial to ensure compliance for affected taxpayers.


What are TicketBAi invoice requirements in Bizkaia?

TicketBAI-compliant software must be able to generate the following documents:

The TicketBAI XML file that records sales operations carried out using TicketBAI software. Taxpayers must generate the TicketBAI XML file just before or as they issue the invoice.

  • The issuance of the TicketBAI XML file must follow the legal format schema, i.e., the sales operation registration XML format or the cancellation XML format.
  • The application of a digital signature and “chaining” of these files are required, meaning that each TicketBAI XML must identify the previously issued invoice using certain elements.

The invoice or supporting document which can be issued in either paper or electronically as per invoice requirements already established by Bizkaia regulations.

  • The invoice generated by the TicketBAI software must incorporate the TicketBAI identifier (unique number code) and TicketBAI QR code using part of the digital signature of the issued TicketBAI XML.

In Bizkaia, unlike in the other Basque regions, taxpayers do not need to send the TicketBAI XML file to the tax authority. Taxpayers will send the relevant file information via the subchapter of invoices issued with guarantor software in the Ledger of Economic Operations (LROE).


How does TicketBAI affect e-invoices?

In Bizkaia, for electronic invoices for relevant transactions to be valid under TicketBAI obligations, they have to be issued by the TicketBAI invoicing software and must contain specific information. The invoices can be issued either paper or electronically in any format as per invoice requirements already established by Bizkaia regulations.

TicketBAI-compliant invoices must also include:

  • QR Code (QR Code on TicketBAI Invoice not required if recipient is a business or professional person or a public Administration and e-invoice is originally issued in a non-readable format (e.g, the facturae format)
  • TicketBAI ID: Unique ID called “Identificativo TicketBAI” is required on the Invoice generated by the TicketBAI software.


Which operations are subject to TicketBAI issuance rules?

TicketBAI software is required for B2G, B2B and B2C transactions. This applies to all operations considered as a supply of goods or provision of services, under Bizkaia VAT law. Any transaction not considered as such is exempt from TicketBAI requirements.


How to comply with TicketBAI invoicing in Bizkaia?

The Bizkaia government has already made the voluntary adoption of Batuz possible. Starting 1 January 2024, taxpayers will be obliged to comply.

Currently, a draft law is being discussed to postpone Batuz obligations, including TicketBAI, for:

  • Small and medium-sized companies
  • Micro-enterprises
  • Self-employed workers
  • Small-sized cooperatives
  • Non-profit entities

As it is still a draft, it needs to be officially published to become effective. The draft, however, does not propose changing the go-live for large companies, which are still expected to comply starting 1 January 2024. For all other groups, a phased implementation is proposed to start on 1 July 2024 and be completed on 1 January 2026.

Taxpayers under the Batuz mandate must develop or acquire TicketBAI-compliant software. They can consult the guarantor software registry, which provides the official list of registered guarantor software.


How to comply with TicketBAI invoicing in Álava

TicketBAI’s implementation in Álava came in phases over 2022, starting with a voluntary period that commenced on 1 January. The mandate came into effect for all on 1 December 2022.

As a result, taxpayers in the province of Álava have to comply with TicketBAI invoicing. It is important to note that TicketBAI compliance does not exempt taxpayers who are also obliged to comply with SII.

To comply with TicketBAI, businesses must have software which generates XML files for each transaction it makes.


How to comply with TicketBAI invoicing in Gipuzkoa

Gipuzkoa’s implementation of its TicketBAI obligation began on 1 January 2021, starting with a voluntary period for taxpayers. The phased roll out of the mandate was made by sectors of activity and ended on 1 June 2023.

In Gipuzkoa, TicketBAI does not exempt taxpayers from their SII obligations.

As with other Bizkaia provinces, relevant taxpayers in Gipuzkoa must use software which generates XML files for transactions.


How Sovos can help with VAT compliance in Spain

Complying with TicketBAI is just one aspect of total VAT compliance in Spain. As previously mentioned in this blog, taxpayers are not exempt from the SII mandate when complying with TicketBAI so it is important to know the rules at play there.

It is also worth noting that TicketBAI is separate from the Spain e-invoicing mandates that are in place across B2G and B2B transactions.

If you need help with VAT compliance in Spain, don’t hesitate and speak to our experts.

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Carolina Silva

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